Superfund Document

PRELIMINARY CLOSE OUT REPORT
FOR THE
HUDSON REFINERY SUPERFUND SITE
CITY OF CUSHING, PAYNE COUNTY, OKLAHOMA
(CERCLIS ID OKD082471988)
U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION 6
DALLAS, TEXAS
November 2010
TABLE OF CONTENTS
I. INTRODUCTION .................................................................................................. 1
II. SUMMARY OF SITE CONDITIONS................................................................... 1
Background ................................................................................................................. 1
Site Investigations and Response Actions .................................................................. 2
Remedial Investigation/Feasibility Study (RI/FS)...................................................... 4
Record of Decision ..................................................................................................... 5
Remedial Design......................................................................................................... 8
Remedial Action and Construction Activities .......................................................... 11
Explanation of Significant Differences..................................................................... 15
III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE
AND QUALITY CONTROL ....................................................................................... 16
IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION ........................ 17
V. SUMMARY OF REMEDIATION COSTS.......................................................... 18
VI. FIVE-YEAR REVIEW..................................................................................... 19
VII. BLIOGRAPHY................................................................................................. 20
Preliminary Close Out Report November 2010 i Hudson Refinery Superfund Site
PRELIMINARY CLOSE OUT REPORT
FOR THE
HUDSON REFINERY SUPERFUND SITE
CITY OF CUSHING, PAYNE COUNTY, OKLAHOMA
I. INTRODUCTION
This report has been prepared to document that the U.S. Environmental Protection
Agency (EPA) has completed all construction activities for the Hudson Refinery
Superfund Site in accordance with Close Out Procedures for National Priorities List
Sites (OSWER Directive 9320.2-09A-P, January 2000), and completion of the remedy
construction consistent with the Record of Decision (ROD). The site remedy
construction was accomplished pursuant to, and in accordance with, the requirements of
the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), 42 U.S.C. 9601 et seq., and consistent with the National Contingency Plan
(NCP), 40 CFR Part 300.
On October 19, 2010, the EPA, the Oklahoma Department of Environmental

Quality (ODEQ) project manager, and a Land OLakes (LOL) representative conducted a
Pre-final inspection. EPA and ODEQ have determined that Land OLakes has
constructed the remedy in accordance with the Remedial Design (RD) plans and
specifications and with the Remedial Action (RA) Work Plan.
II. SUMMARY OF SITE CONDITIONS
Background
The Site is located in the City of Cushing in Payne County, Oklahoma. The
National Superfund Database Identification Number is OKD082471988. The
approximately 200-acre Site is located on the west side of the City of Cushing,
Oklahoma. The Site is bisected by State Highway (SH) 33 with approximately 165 acres
north of SH 33 (North Refinery) and approximately 35 acres south of SH 33 (South
Refinery). The North Refinery is bounded by Depot Avenue to the east, the former
Empire Refinery to the north, Kings Highway to the west, and SH 33 to the south. The
South Refinery is bounded by Depot Avenue to the east, SH 33 to the north, Violet
Avenue to the west, and Moses Street to the south. Residential neighborhoods are
located to the east and west of the Site. There are commercial properties to the east and
south of the Site. The Site remains fenced; access to both the North and South Refinery
is through locked gates.
The Site is an abandoned refinery that operated from 1922 until ceasing operation
in 1982 when the owners declared bankruptcy and abandoned the Site. Few structures
currently remain on the Site and much of the Site was graded following removal actions
in 2002 and 2003. The North Refinery topography slopes to the southeast, and the South
Refinery is relatively flat, but slopes slightly to the northeast. A Resource Conservation
________________________________________________________________________
Preliminary Close Out Report November 2010 1 Hudson Refinery Superfund Site
and Recovery Act (RCRA) Land Treatment Unit (LTU), a biotreatment LTU, unlined
wastewater treatment impoundments, abandoned pipelines, and a few concrete-lined
sumps remained on the Site prior to remedy construction activities. One active pipeline
runs from east/west and bisects the North Refinery.
Over sixty years of refinery operations resulted in environmental contamination at

the Site. The refinery produced liquid propane gas, gasoline, aviation fuel, diesel fuel,
and fuel oils. These production activities generated wastes which resulted in the release
of hazardous substances at the Site. The North Refinery consisted of a refinery process
area, a hydrofluoric acid (HF) alkylation plant, a tetraethyl lead (TEL) building,
associated aboveground storage tanks (ASTs), office, storage, and maintenance buildings,
and treatment ponds. The South Refinery consisted of a refinery process area, a TEL
building, laboratory buildings, ASTs, and an unlined coke pond.
The November 2007 ROD gives a limited description of early refinery operations
and ownership through 1943. Title records show the refinery changed ownership in 1943
when it was acquired by Midland Cooperative Wholesale (later Midland Cooperatives).
The refinery changed ownership again in 1977 when it was acquired by Hudson Oil
Refinery Company and operated by Hudson Refining Company.
The refinery expanded in size during its ownership by Midland Cooperatives.

The refinery quadrupled in size in 1952 with the acquisition of property north of SH 33.
Refinery records and aerial photographs outline construction of processing units on the
southern edge of the portion of the site, north of SH 33, including a fluids catalytic
cracker plant with a polymerization unit, a platformer, an alkylation plant. Additionally,
a delayed coking unit was built on the site south of SH 33. Aerial photographs show an
increase, from the 1954 photograph to the 1969 photograph, in the number of refinery
tanks with the addition of a concrete-lined aeration pond and six unlined wastewater
treatment lagoons covering approximately 40 acres on the north portion of the Site.
During Midland Cooperatives ownership and operation of the refinery, Midland
generated various hazardous substances and wastes, including slop oil emulsion solids,
heat exchanger bundle cleaning sludge, Associated Petroleum Institute (API) separator
sludge, leaded tank bottoms, process waste water, and waste hydrocarbon byproducts.
Midland also operated numerous unlined waste ponds and pits, oil skimming ponds, an
unlined coke pond, sumps, unlined settling ponds, cooling ponds, holding ponds and
drainage ditches/berms for waste disposal. In addition, product and chemical spills and
leaks occurred from tanks, ditches/berms, process units and waste areas.
Site Investigations and Response Actions
Refining operations ceased in 1982 and the Site was abandoned. Hudson Oil
Company filed for bankruptcy in January 1984. On August 8, 1984, the Department of
Justice filed a complaint on behalf of the EPA, alleging violations of RCRA statutory and
regulatory requirements (E&E, 1999). A Final Consent Decree was filed in 1987, which
required corrective actions including tank clean out, soil excavation, removal of sludges
and soils from a pond located on the North Refinery, the North Oily Water Pond
________________________________________________________________________
(NOWP), and biotreatment of contaminated soils, ground water remediation, and ground
water monitoring at the LTU (ODEQ, 2003).
Since the early 1980s, areas of the Site have been sampled pursuant to the
requirements of the 1987 Final Consent Decree or RCRA compliance monitoring. After
Consent Decree funds allocated for the cleanup were depleted on November 30, 1993,
Hudson filed a motion in the United States District Court of the Western District of
Oklahoma (Court) to terminate the Final Consent Decree. The Court recognized that all
of the requirements of the Final Consent Decree had not been met; however there were
no financial resources remaining, so the Court moved to release Hudson from the
obligations of the Final Consent Decree (E&E, 1999). An Order of Closure of the Final
Consent Decree was issued in 1994 (ODEQ, 2003).
As part of the proposed relocation of SH 33 through the Hudson Refinery, an

Initial Site Assessment was performed by the Oklahoma Department of Transportation
(ODOT) to identify the potential of encountering hazardous wastes during highway
construction. Eight soil boring samples were taken from zones reported as exhibiting
strong petroleum odors found in 14 areas. During soil sampling, carbon disulfide,
styrene, naphthalene, and 2-methylnaphthalene were detected and petroleum product was
observed floating on ground water as it filled the boreholes. (ODOT, 1991).
In 1995, soils samples were collected for an EPA Site Inspection. These samples
indicated inorganic constituents and organic polynuclear aromatic hydrocarbons (PAHs)
at the Site. The Site Inspection Prioritization Report also documented that 28,000 pounds
of chemicals, including HF, TEL, solid chlorine (hypochlorite), and ethylene dichloride,
were stored in on-site buildings (ODEQ, 2003 and Shaw, 2004).
In November 1997, ODEQ requested EPAs assistance on the Site (ODEQ, 2003).
Two joint inspections conducted by EPA and ODEQ in 1998 identified open, leaking
tanks, stained soil, and debris, damaged and friable asbestos-containing material (ACM)
hanging from the refinery vessels and pipes, overflowing ASTs and separators, and
numerous deteriorated leaking drums and smaller containers of unknown materials.
In April 1998, Cushing Middle School students started a letter writing campaign
to get public officials to investigate the abandoned refineries in the vicinity of Cushing.
In September 1998, EPA contractors began emergency cleanup activities. Initial removal
activities were focused on the South Refinery and included investigation of radiation
sources, demolition of structurally unsafe buildings, removal of TEL, ACM abatement,
and disposal of waste containing CERCLA hazardous substances. In addition, removal
activities included excavation of oil-contaminated soils; removal of product from ASTs,
separators, and sumps; construction of a bioremediation land-treatment unit; and
biotreatment of Oil Pollution Act (OPA) wastes. Some removal activities occurred on the
North Refinery and included the dismantling of HF alkylation unit which included
approximately 5,600 gallons of product, removal of all catwalks from the towers that
were left standing, and the removal of TEL ASTs.
________________________________________________________________________
Based on the investigation and analytical results from sampling that EPA
performed as part of an Expanded Site Inspection in 1998, the Site was placed on the
National Priorities List on July 22, 1999.
On August 10, 1998, the Superfund Division Director, gave oral approval for the
expenditure of up to $1 million to initiate an emergency removal action on the known
existence of 23,000 square feet of loose and friable ACM on the South Refinery. On
November 12, 1998, the Director orally approved an additional $750,000 to address the
most immediate threats posed by the HF alkylation unit. On March 24, 1999, EPA
signed a Removal Action Memorandum to perform the emergency cleanup activities on
both the North and South Refineries. The Removal Action Memorandum documented
EPAs determination that the Site presented an imminent and substantial threat to public
health and the environment.
On September 25, 2001, EPA signed a non-time critical Removal Action

Memorandum to remove or eliminate principal threat wastes, thereby eliminating or
reducing risks from potential exposure pathways from those wastes, at the site. From
September 2002 through June 2003, EPA conducted a non-time-critical removal action.
The areas addressed in this removal action were the: 1) superstructures, refinery process
units containing potential hazardous chemicals and substances; and 2) miscellaneous
items, including unlined collection basins, a sump, and structurally unsafe buildings.
Existing refinery process equipment and structures were dismantled and removed from
the site. Friable ACM was removed from process equipment and piping in coordination
with decontamination and removal activities. Decontamination and removal of the
process equipment required a three-step process that consisted of first draining or
evacuating residual liquid contents, followed by disassembly and removal of the
equipment, and finally a thorough cleaning of the equipment to remove residual sludge
and solids. Few structures currently remain on the site.
Remedial Investigation/Feasibility Study (RI/FS)
Through a State Cooperative Agreement, ODEQ had the lead on conducting the
RI/FS for the Site. From 2004 through 2007, ODEQ conducted a RI/FS. The RI
identified the types, quantities, and locations of contaminants and the FS developed ways
to address the Site contamination.
From early 2005 through early 2007, contractors for the ODEQ conducted a
RI/FS including field sampling and investigation activities of soil, sediment, surface
water, ground water, and fish tissue. The RI/FS reports identified the types, quantities,
and locations of contaminants found in these samples and developed ways to address the
contamination. In addition, a Human Health Risk Assessment and an Ecological Risk
Assessment were performed to determine the current and future effects of contaminants
on human health and the environment.
Onsite hazardous substances and contamination were identified in soil, sediment,

surface water, and ground water. Waste materials, visual contamination in soil, coke tar
________________________________________________________________________
and coke tar contaminated soil, ACM, and light non-aqueous phase liquid (LNAPL) were
found at the site. The RI also identified public safety hazards presented by Aeration Pond
7, associated sumps, the electrical vault, and scrap metal.
Benzo(a)pyrene (BaP), arsenic, and lead were the principal contaminants of

concern (CoCs) in soil. BaP and benzo(a)anthracene (BaA) were the principal CoCs in
sediment. BaP was identified the principal CoC in waste pond surface water. Benzene
and thallium were identified as the principal CoCs in ground water. Additionally,
LNAPL was identified on ground water in one monitoring well.
Record of Decision
After review and response to comments, the ROD was signed on November 23,
2007. Remedial Action Objectives (RAOs) were developed in the FS for the Site by
medium. Areas of Concern (AOCs) were then developed for each media. The RAOs
from the ROD are listed below:
Table 1 Remedial Action Objectives

Soil
Prevent exposure to current and future human receptors and ecological receptors through direct contact
with, inhalation, or ingestion of contaminated soil that exceeds a Hazard Index greater than 1 or in excess
of 10-5 excess cancer risk.
Waste Pond Sediment
with and ingestion of contaminated waste pond sediment that exceeds a Hazard Index greater than 1 or in
excess of 10-5 cancer risk.
Waste Pond Surface Water
with and ingestion of contaminated waste pond surface water that exceeds a Hazard Index greater than 1 or
in excess of 10-5 cancer risk.
Ground Water and LNAPL
Restore ground water to drinking water quality by attaining the National Primary Drinking Water MCLs for
ground water COCs.
Prevent LNAPL from moving off-site and/or discharging into surface water bodies.
Reduce or eliminate the potential for ground water to be impacted by contamination located in the
subsurface by removing LNAPL from the ground water until the performance standard (a threshold
thickness of 0.1 foot of LNAPL, measured using an interface probe in monitoring or extraction wells) is
attained. (USEPA, 1986b)
Other Media
Prevent unacceptable exposure risks to current and future human populations from the inhalation or
ingestion of ACM or associated contaminated materials.
Eliminate and prevent further degradation of the surrounding environment as a result of exposure to coke
tar and coke tar contaminated soil.
Eliminate and prevent human health, environmental and public safety hazards presented by aeration pond
7, associated sumps, the electrical vault, and scrap metal.
In order to achieve these RAOs, numerical risk-based cleanup levels were

established for each environmental medium based on a commercial/industrial scenario as
shown in Table 2:
________________________________________________________________________
Table 2 Cleanup Levels for Contaminants of Concern
Chemical of Cleanup Level Basis for Cleanup Level Risk at Cleanup Level
Concern
Media: Soil
Site Area: Soil Areas of Concern 1 through 7 and ACM Area
Lead 1000 mg/kg EPA Adult Lead Methodology N/A
2006 ODEQ Site Risk-
within EPA cancer risk range
Management Decision
of 1E-06 to 1E-04, and below
Arsenic 31.8 mg/kg Memorandum normalized
the non-cancer Hazard Index
background concentration plus 3
of 1
standard deviations
Benzo(a)pyrene 4.22 mg/kg Human Health Risk Assessment 1.0E-05
40 CFR Part 61 Subpart M
ACM >1% asbestos N/A
current detection level for ACM
Media: Sediment
Site Area: Wastewater Ponds and Coke Pond
Benzo(a)anthracene 42.2 mg/kg
Human Health Risk Assessment
1.0E-05
Results
Media: Surface Water

Site Area: Wastewater Treatment Ponds and Coke Pond
Media: Ground Water
Site Area: Site-Wide
Benzene 5.0 g/l National Primary Drinking Water N/A
MCL
Thallium 2.0 g/l National Primary Drinking Water N/A
MCL
Media: Ground Water
Site Area: Site-Wide
LNAPL 0.1 foot thickness EPA guidance and common N/A
engineering practice
Note: mg/kg milligrams per kilogram
g/l micrograms per liter
N/A Not Applicable
MCL Maximum Contaminant Level
The ROD addressed the Site as one operable unit. The ROD final response action
addressed Site hazardous substances, pollutants, or contaminants, visual contamination,
and waste material through the following:
Approximately 32,000 cubic yards of contaminated soil in the South and North
Refineries - excavated and transported to an appropriate off-site permitted
landfill.
________________________________________________________________________
Approximately 21,000 cubic yards of waste pond sediment - dewatered,
stabilized, as needed, excavated, and transported to a permitted off-site disposal
facility. Sediment was considered a principal threat waste at the Site.
Surface water volume varied significantly with rainfall additions to and
evaporation from the waste ponds. For ROD cost estimate purposes it was
assumed that 7.5 million gallons would need to be treated.
Approximately 10 cubic yards of waste pile ACM - excavated, containerized, and
transported to a regulated off-site disposal facility.
Approximately 6,000 cubic yards of coke tar - excavated, stabilized, and
transported to a regulated off-site disposal facility. Coke tar was considered a
principal threat waste at the Site.
Approximately 4,955 cubic yards LNAPL was to be removed through use of
hydrocarbon belt skimmers. LNAPL is currently located in one well on-site.
LNAPL was considered a principal threat waste at the Site.
A ground water restoration monitoring program would be developed during the
remedial design to monitor ground water until cleanup levels are achieved.
Ground water should be monitored to ensure that ground water contamination
does not migrate beyond Site boundaries and to ensure that the areas with
contamination are stable and/or decreasing.
Material, including tanks and metal debris, that remains at the Site would be
removed and salvaged.
Results from toxicity characteristic leaching procedure (TCLP) analyses was
required for determination of disposal requirements for Site waste and
contaminated media at an appropriate off-site permitted landfill.
The process and tanks areas of the Site will be available for a reasonably
anticipated reuse of commercial/industrial; therefore, Institutional Controls (ICs) are
required to aid in the management of waste left on-site for each site media listed above.
At the time the ROD was signed, most of the Site property was owned by local citizens.
The ROD language stated,
ICs will include deed notices placed on land parcels that are contained in the
Site. The deed notices will identify the reason for the notice, the affected
property, the remedy, engineering controls, land use restrictions, and ground
water use restrictions prohibiting use of the shallow ground water. An easement
may also be granted by the landowners for continued remedial response. The
deed notices will be filed by the ODEQ should the property owner decline. The
ICs will be implemented and monitored by the ODEQ. The city currently has an
ordinance in place that prohibits Site access. Exceptions during RA construction
included EPA, ODEQ, federal/state remediation contractors, LOL, and its
representatives and remediation contractors until completion of Site cleanup.
Current Site zoning is for industrial use.
The remedial action set forth in the ROD was consistent with, and complied with,
the Superfund Amendments and Reauthorization Act (SARA) of 1986, P.L. 99-499,
which substantially amended CERCLA, 42 U.S.C. 9601 et seq., and the NCP. SARA
codified many of the existing requirements under the then existing NCP (1985), as well
________________________________________________________________________
as adding, among other things, a new Section 121 to CERCLA, which provided direction
for selection of remedial actions compliant with applicable or relevant and appropriate
Federal, State, and Local laws regulations and requirements, 42 U.S.C. 9621.
Based on the investigation of Site historical information, five Special Notice

letters were issued to individuals, groups of individuals, and one company identified as
potentially responsible parties (PRPs).
LOL, Inc., a Minnesota corporation, is the surviving corporation of Midland,

based upon a December 24, 1981, merger agreement between Midland Cooperatives,
Inc., and LOL. A Unilateral Administrative Order (UAO), signed January 6, 2009, was
sent to the company, LOL, requiring it to implement the Site remedy outlined in the
ROD. A conference, as requested by the UAO Respondent, was held February 3, 2009,
to discuss issues involved with the implementation of response actions. This opportunity
to confer was outlined in Section XXIV of the UAO. The UAO became effective date 30
days after signature of the order.
On February 10, 2009, EPA received from LOL, a Notice of Intent to Comply
with the UAO. LOL also identified a Project Manager and Project Coordinator and
submitted a Quality Management Plan (QMP) as required by the UAO.
EPA issued authorization to proceed on April 20, 2009, upon approval of the
QMP submitted by LOLs environmental contractors. LOL selected the team of The
Benham Companies, LLC (Benham) and Envirocon, Inc. (Envirocon) to perform the RD
and RA components, respectively, of the UAO and Statement of Work (SOW). EPA and
LOL agreed in August 2009 to attempt an accelerated schedule for the RD/RA, with the
goal of completion by September 15, 2010. The EPA Remedial Project Manager (RPM)
and the ODEQ Project Manager participated in a scoping meeting with the PRP
contractors on April 21, 2009. This meeting kicked off the work for the RD for
implementation of the ROD.
Remedial Design
The LOL contractor, Benham, prepared the RD as required by the UAO and UAO
Attachment 3, SOW. The selected remedy required excavation of contaminated soil,
sediment, coke tar, scrap metal, ACM and disposal at an appropriate landfill(s).
Benham submitted the final RD Work Plan and associated documents to EPA on
August 21, 2009; EPA approved the RD Work Plan on September 4, 2009. The RD
outlined plans for LOLs implementation of the selected remedy of excavation of
contaminated soil, sediment, coke tar, scrap metal, ACM, disposal of these materials at an
appropriate landfill(s), and coordination with ODEQ to place deed restrictions on
remediated Site property. Please find general site figures in Attachment 1.
As noted in the ROD section of this report, the selected remedy also required
institutional controls to aid in the management of the wastes left on-site and to notify
________________________________________________________________________
current and potential future deed holders through deed restrictions of the presence of
wastes left on-site. LOL purchased a significant portion of the Site property during the
RD and RA work; as a property owner, LOL would be responsible for filing deed
notice(s) on property it owns. As noted in the RD Work Plan, LOL indicated plans to
work with EPA and ODEQ on the format, content, preparation, and filing of the deed
notices.
The RD Work Plan included a plan for environmental sampling to better define
the areas of soil, sediment, surface water, and ground water contamination at the Site
identified in the ROD. This additional sampling and analysis was designated as the
Supplemental Field Investigation (SFI). The field work for SFI was conducted by
Benham in September and October 2009.
Benham submitted the Pre-Final Design on February 1, 2010, and submitted a

revised Pre-final Design document on March 11, 2010, revised in response to EPA
comments. EPA noted typographical or document consolidation errors in some of the
revised Pre-final documents. A corrected Pre-Final Design was submitted March 29,
2010, and approved by EPA on April 9, 2010. Upon EPA approval, the Pre-final Design
was deemed the Final Design and was incorporated into the UAO as a requirement of the
UAO and became an enforceable part of the UAO. The RD provided a detailed
description of LOLs implementation of the selected remedy of excavation of
contaminated soil, sediment, coke tar, scrap metal, ACM waste pile, disposal of these
materials at an appropriate landfill(s), and coordination with ODEQ to place deed
restrictions on remediated Site property.
The RD contained the results of the SFI media and waste characterization and the
volume of waste and contaminated material as estimated by Benham. Pothole sampling
was also conducted in October 2009 to better define areas with visual contamination in
ROD soil areas of concern (SAOC).
As noted above, Benham sampled ground water during the SFI sampling. During
the RI, ground water contamination was found to be discontinuous and in isolated areas
on the Site; monitoring was determined to be the most cost effective remedial alternative.
Monitoring well OW-D was identified in the RI as the one monitoring well with LNAPL.
The accumulated LNAPL was removed using tubing and a peristaltic pump during SFI
sampling. Ground water monitoring was scheduled to be conducted on a quarterly basis
during the RD and RA construction activities. LNAPL in monitoring well, OW-D, had
not returned as of the date of approval of the RD; continued quarterly monitoring was
planned for this well at the same sampling schedule as other Site wells during RA
construction work.
The RD described the intended use of berm material in between the North
Refinery wastewater ponds as a backfill borrow source. The ROD required excavated
areas to be backfilled with clean soil, graded for adequate drainage, and the surface of the
soil seeded to establish a vegetative cover ore re-vegetated. Use of the on-site berm
material meant that backfill borrow material would not have to be purchased from an off-
________________________________________________________________________
site source. This resulted in a cost savings. The RD included sampling required to show
that the berm material was suitable for use as a backfill borrow source.
The Basis of Design section in the RD described pond drainage to expose

contaminated sediments and waste pond surface water treatment to meet the ODEQ
discharge authorization and it described excavation of soil, sediment, and waste in the
coke tar area and stabilization, treatment, and haul-off of waste and contaminated media
to an appropriate landfill. It also included a description of basic procedures to address
ACM and scrap and tank metal, and included a preliminary grading plan for the
wastewater treatment pond area to create an open area with fewer steeply sloped surfaces
that would reduce downstream impacts, the potential for shallow ponding, and facilitate
ongoing maintenance.
The grading plan included differences from the ROD plan for the North Refinery
ponds. Wastewater Pond 6 did not have contaminated sediment; it would be modified
and left open to provide storm water retention for flow from the former wastewater pond
area to minimize downstream flooding. Treatment Pond 8 and Runoff Pond 9 would be
modified and combined for storm water retention for flow channeled from the South
Refinery to minimize downstream flooding. Storm water retention would hold excess
storm water and release it more slowly into Skull Creek after rain events. Also by not
backfilling Wastewater Pond 6, Treatment Pond 8, and Runoff Pond more berm material
remained available for soil excavation backfill.
Additional documents, as required by the SOW, were submitted with the Pre-
Final Design or as part of the Pre-final Design package. These documents included
Final Field Sampling Plan (FSP) submitted on April 30, 2010. The FSP included a
document Benham called Supplemental Work Plan for Hot Spot Analysis and Post-
Excavation Confirmation Sampling Plan. This supplement sampling work plan included
sampling locations within the SAOCs for confirmatory soil sampling to determine
compliance with ROD performance standards. The proposed RA construction schedule
submitted with the Pre-final RD showed a demobilization date of September 15, 2010.
The data for surface water from the SFI indicated that all site wastewater pond
surface water met the ROD-required cleanup levels for BaP. Soil and sediment sampling
results indicated that these media did not exceed TCLP criteria; therefore, it was
determined that stabilization was not required to meet TCLP landfill criteria.
During the RD process, LOL evaluated two surface water disposal options,
through discharge to Skull Creek and through disposal at the Cushing wastewater
treatment plant. Benham submitted the results from water pond surface water sampling
to ODEQ to determine discharge requirements for discharge of the water to Skull Creek.
The results were also submitted to the City of Cushing to determine pretreatment
requirements for disposal of the water at the Cushing wastewater treatment plant.
Discharge limits and monitoring frequencies were provided by ODEQ on November 23,
2009.
________________________________________________________________________
Remedial Action and Construction Activities
To expedite Site RA activities, Envirocon submitted RA work plans in phases.

Phase I included Site clearing and grubbing and removal of tanks, scrap metal, and
piping. Phase II addressed soil, sediment, and coke tar contamination, and included
ACM abatement. ACM abatement was originally to be included as part of Phase I;
however, additional ACM was found at the site during clearing and grubbing activities
and during surface piping work. Envirocon submitted the preliminary RA work plan for
clearing and grubbing on November 25, 2009; it was approved by EPA on December 2,
2009. Envirocon submitted the preliminary RA work plan for removal of tanks, scrap
metal, and exposed piping on November 25, 2009; after addressing EPA comments the
plan was revised and approved by EPA on December 5, 2009.
The draft RA Work Plan for Phase II Site-wide work was submitted on May 3,
2010. It was approved with modifications by EPA on May 13, 2010. The UAO required
In the event of approval or approval with modifications by EPA, the Respondent shall
proceed to take any action required by the plan, report, or other item, as approved or
modified by EPA. The work described in the draft RA Work Plan was approvable. A
revised RA Work Plan was submitted May 28, 2010, and approved by EPA on June 8,
2010. Upon EPA approval, the RA Work Plan was incorporated into the UAO as a
requirement of the UAO and became an enforceable part of the UAO. The schedule
submitted with the RA Work Plan included a site construction work completion and
demobilization date of September 15, 2010.
Mobilization to the site for Phase I remedial construction activities began

February 28, 2010. The Phase I mobilization effort addressed Site clearing and grubbing
and removal of tanks and scrap metal. Tapping and draining of exposed pipes was
completed during this Phase I effort. Tapping and draining of pipes encountered during
excavation and scrap metal removal continued into RA Phase II, as needed. Mobilization
to the site for Phase II construction activities began June 1, 2010. Phase II addressed soil,
sediment, and coke tar contamination, and included ACM waste pile abatement. Ground
water monitoring started prior during the development of the RD Work Plan continued
quarterly monitoring was planned for this well at the same sampling schedule as other
Site wells. The following paragraphs provide a brief overview of the excavation of
contaminated soil, sediment, coke tar, scrap metal, ACM, disposal of these materials at an
appropriate landfill(s), and the pre-final inspection conducted on October 19, 2010.
Monthly Progress Reports and Weekly Communications Memos were prepared

by Benham/Envirocon during implementation of the work to document the progress of
remedial construction.
Sampling of the North Refinery wastewater treatment ponds berm material was
conducted April 30, 2010, and May 3, 2010. The results indicated that the wastewater
treatment pond berms were suitable as an excavation backfill borrow source.
________________________________________________________________________
Hot spot analysis soil sampling described in the Supplemental Work Plan for
Hot Spot Analysis and Post-Excavation Confirmation Sampling Plan was conducted
May 3, 2010, through May 10, 2010. The results from this sampling added additional
areas for remediation to the areas identified in the SFI.
As noted in the RD section, surface water sampling conducted during the SFI
indicated that surface water did not exceed ROD cleanup levels. The former refinery
treated process and wastewater from Aeration Pond 7 through the wastewater pond series
to Wastewater Pond 6 where it was discharged to Skull Creek. This same flow path was
used when surface water was pumped to expose sediments for remediation through the
wastewater pond series. Moving the surface water through the wastewater ponds also
served to settle suspended solids prior to discharge in an effort to meet ODEQ discharge
authorization parameters. Results from initial surface water discharge monitoring
showed suspended solids levels exceeded ODEQ discharge authorization levels. A sand
filtration unit was set up to treat water from Wastewater Pond 6 to reduce suspended
solids load to Skull Creek and meet the ODEQ discharge authorization. Process and
wastewater from the South Refinery was channeled to the North Refinery to a former
holding pond in the general area of Treatment Pond 8 and Runoff Pond 9. When surface
water from the Coke Pond was being moved to Runoff Pond 9 unacceptable levels of oil
and grease were observed in the water. Frac tanks were brought on-site to treat Coke
Pond surface water before channeling to Runoff Pond 9.
As described in the ROD, solidification measures were required for wastewater

pond and Coke Pond sediments. The RD described that sediment results indicated low
percent solids content and that the sediment from the ponds would be solidified as needed
by mixing with soil obtained from the pond berms so as to be acceptable to the receiving
landfill. During the RA, it was determined additives were needed to solidify wastewater
pond sediments for excavation and load-out for disposal. Berm and pond bottom soil was
not enough to solidify the sediments; fly-ash was imported from the receiving landfill for
use in sediment solidification.
The ROD and RD described that confirmation sampling was needed during
remedial activities to verify the classification of the waste for disposal. Confirmation
sampling of soil excavations in three areas in SAOCs 1 and 2 revealed lead exceedences
high enough that TCLP criteria were exceeded. These areas required re-excavation and
re-sampling to ensure ROD performance standards were met and per procedures outlined
in the RD and FSP. The re-excavated areas required blending and TCLP re-analysis prior
to landfill disposal. The excavated soil had to pass TCLP before the landfill would
accept the material.
During soil confirmation, sampling to determine if ROD cleanup levels had been
met, soil excavated from certain SOAC in four areas in SAOCs 1 and 2 revealed lead
exceedences high enough that TCLP criteria were exceeded. These areas required re-
excavation and re-sampling to ensure ROD performance standards were met and per
procedures outlined in the RD and FSP. The re-excavated areas required blending and
TCLP re-analysis prior to landfill disposal. The excavated soil had to pass TCLP to
________________________________________________________________________
verify the classification of the waste for disposal and before the landfill would accept the
material.
During Site clearing and grubbing and RA construction activities, an additional

ACM waste area was identified adjacent to and west of the ACM waste pile noted in the
ROD. Two surface ACM wrapped pipes were also identified. The asbestos abatement
contractors addressed the original ROD waste pile, the ACM waste area to the west, and
the two ACM wrapped pipes. Removal of the ACM waste pile and ACM waste area
were completed the last week in August 2010 and passed confirmation sampling with the
method and lower detection levels specified in the Framework for Investigating
Asbestos-Contaminated Superfund Sites OSWER Directive #9200.0-68, September
2008. The total value of 460.82 cubic yards of ACM impacted soil/debris was removed
from the Site and properly disposed. A total of 719 linear feet of ACM wrapped pipe was
removed from site. The piping weighed 1.7 tons.
A Remediation Summary table was produced weekly to identify the status of

excavation, haul-off, and confirmation sampling of Wastewater Treatment Ponds 1, 2,
and 3, Aeration Pond 7, Coke Pond, Coke Tar Area, and the SAOCs. The Remediation
Summary also included running volume totals of contaminated soil, sediment, and coke
tar waste hauled off-site for disposal. The final volumes are included in the final
Remediation Summary. The October 12, 2010, final Remediation Summary is included
in Attachment 2. Two totals are listed in the Remediation Summary: 54,719 cubic yards
includes contaminated soil, contaminated sediment, and coke tar and 61,168 cubic yards
includes construction debris. The term construction debris was used by the landfill
for general debris, building material, and contaminated soil mixed with concrete chunks,
brick, and metal waste. The estimated volume of construction debris removed during the
RA was 3,294 cubic yards calculated at 2.2 tons per cubic yard. Scrap metal, tank metal
and piping weight hauled off-site for recycle or disposal was logged separately. The final
weight for scrap metal, tank metal and piping was 242.62 tons.
LOL sent a Notice of Anticipated Delay on September 10, 2010. Through this
letter, they notified EPA that the September 15, site construction work completion and
demobilization date of September 15, 2010, would not be met. LOLs notice included a
RA Work Plan schedule revision with a site construction work completion and
demobilization date of November 15, 2010. EPA agreed with Land OLakes request to
revise the schedule based on its description of the unexpected numbers and volumes of
buried pipes, pipe contents, and concrete structures encountered during excavations on
the South Refinery and delays due to inclement weather. EPA approved the schedule
submitted by LOL with modifications in accordance with UAO provisions. The schedule
provided by LOL which projected completion of all waste removal from the Site by
October 18, 2010, and site demobilization by November 15, 2010, was determined to be
incomplete. Modifications to the schedule needed to include projected completion dates
for RA actions required to meet UAO requirements and ROD performance standards,
clean up levels, and RA objectives up to the point where long-term response for ground
water is started. LOL submitted a revised schedule which is currently under EPA and
ODEQ review.
________________________________________________________________________
Contaminated soils and sediment, coke tar, ACM waste, scrap, and tank metal
were removed from the Site on or before October 6, 2010. Confirmation sampling was
conducted per the FSP to determine that ROD cleanup levels had been met. Final soil
confirmation sample results were received October 19, 2010, and reviewed by EPA on
October 24, 2010.
Ground water monitoring was conducted on a quarterly basis through the RA

construction activities and is continuing. The July 2010 ground water monitoring results
were submitted to EPA on October 17, 2010. The results package included a request to
remove the requirement for thallium monitoring. Section 24.1 of the ROD describes
reevaluation of thallium to determine if it is a regional or background constituent.
Thallium was not detected at analytical levels well below ROD cleanup levels for four
quarters of monitoring. EPA agreed with LOLs request to discontinue thallium
monitoring. Ground water monitoring will continue as part of Site long-term response
and operation and maintenance until cleanup levels are met. Ground water should be
monitored to ensure that ground water contamination does not migrate beyond Site
boundaries and to ensure that the areas with contamination are stable and/or decreasing
The ROD estimated time to reach RAOs was 30 years. LNAPL has not returned to
monitoring well OW-D; but LNAPL below the cleanup level was found in monitoring
well MW-4. Monitoring and evaluation of LNAPL presence will continue for all wells
included for long-term response.
Institutional controls are required to aid in the management of the wastes left on-
site and to notify current and potential future deed holders through deed restrictions of the
presence of wastes left on-site. As a property owner, LOL would be responsible for
filing deed notice(s) on property it owns. As noted in the RD Work Plan, LOL indicated
plans to work with EPA and ODEQ on the format, content, preparation, and filing of the
deed notices. The deed notices should be filed shortly after demobilization of equipment
from the Site (within 60 days). Field notes, survey logs, and sampling information from
the RA will aid in establishing notices placed on land parcels that are contained in the
Site. The deed notices will identify the reason for the notice, the affected property, the
remedy, engineering controls, land use restrictions, and ground water use restrictions
prohibiting use of the shallow ground water.
A pre-final inspection was conducted by EPA and ODEQ at the site on October
19, 2010, following completion of excavation and transportation offsite of contaminated
material. A copy of the EPA inspection record is provided in Attachment 3.
The following RA work items were determined to be complete:
Clearing and Grubbing;

Excavation of waste, contaminated soil and sediment, coke tar;
Offsite disposal of wastes, contaminated soils and sediments, coke tar;
Surface water discharge;
Confirmation and Waste Profile Sampling;
________________________________________________________________________
Backfill and preliminary grading of the excavated areas on the North
Refinery; and
Backfill and preliminary grading of the excavated areas on the South
Refinery.
During the pre-final inspection, the ODEQ and EPA determined that the
following RA work punch-list items remained incomplete:
Disking and re-vegetation/seeding of the backfilled/graded areas on the

North Refinery with fescue;
Final grading, elimination of areas that may hold water, and survey;
Re-vegetation/seeding of the backfilled areas on the South Refinery with
fescue;
Erosion control measures through winter;
Completion of pond grading;
Completion of drainage outfalls;
Replacement and repair of Site fencing;
Demobilization of heavy equipment and Site trailers;
Site mowing;
Management of Site through winter months;
Springtime re-vegetation/seeding with permanent cover (Bermuda) and
any needed erosion control measures (including replacement of sod on
sloped areas);
Filing of Institutional Controls;
Update of Surface Water and Ground Water Monitoring Plan for well
installation;
Installation of wells to ensure LNAPL ROD performance standards are
met;
Installation of wells to ensure benzene ROD performance standards are
met;
Evaluation of Site wells for ground water monitoring for benzene and
LNAPL; P&A all Site wells not used for monitoring or as part of O&M;
Update of O&M Plan; and
Progress reports.
Bullets one through nine were addressed by November 12, 2010. Bullet four
Erosion control measures through winter, bullet nine Site mowing, and bullet ten
Management of Site through winter months will continue as required or needed
through 2011. Bullets eleven through seventeen remain to be completed.
Explanation of Significant Differences
An Explanation of Significant Differences (ESD) was signed on November 19,

2010. The Superfund Program allows for changes in the remedy presented in the ROD if
the remedial action taken differs significantly from the remedy selected in the ROD with
________________________________________________________________________
respect to scope, performance, or cost. Significant Changes are those changes that
generally involve a change to a component of the selected remedy, but do not
fundamentally alter the overall cleanup approach. Work for some of the changes was
completed prior to the ESD being signed. LOL is responsible for performing any
additional work required in the ESD consistent with the terms of UAO. The ESD
outlined six significant changes from the ROD; it also documented minor changes. The
significant changes include:
Wastewater Pond 6, Treatment Pond 8, and Runoff Pond 9 will remain in service
following Site remediation so that during a given precipitation event, storm water
runoff from the Site will not be discharged to Skull Creek at higher flow rates
than would currently occur for a like precipitation event;
ACM volume addressed during RA construction increased in volume from the
ROD estimate;
The volume/weight of tank and scrap metal debris, along with excavated piping,
addressed during RA construction increased from the ROD estimate.
Thallium monitoring has been removed from ground water monitoring
requirements.
Site wells which will not be part of operation and maintenance activities for
ground water monitoring will be required to be properly plugged and abandoned.
Site ownership has changed which affects filing of institutional controls required
by the ROD.
The ESD will become part of the Administrative Record file in accordance with
NCP 40 CFR 300.825(a)(2).
III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE

AND QUALITY CONTROL
The EPA and ODEQ conducted continued oversight during RA construction

activities to determine compliance with quality assurance and quality control (QA/QC)
protocols and the Construction Quality Assurance Plan. Construction activities at the
Site were determined to be consistent with the ROD and adhered to the approved quality
assurance plan which incorporated all EPA and State requirements. Confirmatory
inspections, independent testing, audits, and evaluations of materials and workmanship
were performed in accordance with the technical specifications and plans. An
independent quality assurance contractor, hired by LOL in accordance with EPA
guidance, visited the site during construction activities to review construction progress
and evaluate and review the results of QA/QC activities. No significant deviations or
non-adherence to QA/QC protocols, or specifications were identified.
The quality assurance project plan incorporated all EPA and State QA/QC
procedures and protocols. All monitoring equipment was calibrated and operated in
accordance with the manufacturers instructions. EPA analytical methods were used for
all confirmation and monitoring samples during RA activities. Contract laboratory
________________________________________________________________________
program-like procedures and protocol were followed for soil, sediments, and water
analyses during the RA using private laboratories.
EA Engineering (EA) was the EPA oversight contractor for RA Site activities.
The oversight contract contained provisions for performing split sampling during
remedial activities in order to verify that remedial objectives were met, to ensure quality
control and assurance for all excavation and construction activity, and to ensure
protection and safety of the public and the environment. EA split environmental samples
on selected ground water, sediment, and soil sampling conducted by Benham to ensure
that sampling was conducted in accordance with approved sampling plans and analyses
were conducted by certified laboratories. EPA analytical methods were utilized for all
confirmation and record samples collected by EA during the RA.
The non-hazardous wastes, contaminated soils and sediments, coke tar, and
construction debris were sent to the American Environmental Landfill, 212 South 177th
West Avenue, Sand Springs, Oklahoma. Scrap metal, tank metal, and piping were sent to
Ponca Iron and Metal (a subsidiary of The Yaffee Companies Inc.), 200 East Oakland
Rd., Ponca City, Oklahoma. Sampling was conducted in accordance with the Site Final
Field Sampling Plan and all confirmation analytical results are below the established
cleanup levels for an industrial reuse scenario. In addition, all backfill confirmation
sample results met the established cleanup levels for an industrial reuse scenario. All
analytical data were validated and independently reviewed, and the EPA and the State
determined that analytical results were accurate to the degree needed to assure
satisfactory execution of the RA.
IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION
The following RA work activities will be completed according to the schedule

presented in Table 3 below:
________________________________________________________________________
Table 3: Tasks to be Completed
Task Estimated Completion Responsible Organization
Punchlist Items (except items June 2011 LOL
specifically listed below)
Filing of Institutional May 2011 date indicated on ODEQ/LOL
Controls LOL revision to RA Work Plan
schedule
Update O&M Plan June 2011 date indicated on LOL
LOL revision to RA Work Plan
schedule
Additional Pre-final Summer 2011 and Fall 2011 EPA/ODEQ/LOL
Inspections
Pre-certification Inspection Per paragraph 75 of UAO EPA/ODEQ/LOL
Interim RA Report submittal 30 days after pre-certification LOL
inspection
PRP Long-term Response After completion and EPA LOL
approval of Interim RA Report
Five-Year Review February 28, 2015 EPA/ODEQ/LOL
Complete Final RA Report Per paragraph 76 of UAO LOL
Final Close Out Report As described in EPA guidance EPA
V. SUMMARY OF REMEDIATION COSTS
The original cost estimate to implement the RA described in the ROD was as
follows in Table 4:
Table 4: Estimated Cost for the Selected Remedy

Total Capital Annual O&M
Present Worth Cost
Cost Cost
Soil $3,532,830 $0 $3,535,397
Waste Pond Sediment $4,581,330 $0 $4,619,897
Waste Pond Surface Water $345,120 $0 $352,403
Light Non-Aqueous Phase
$37,200 $10,800 $124,260
Liquid
Ground Water $80,880 $29,520 $335,829
Asbestos Containing Material $13,440 $0 $16,523
Coke Tar $619,984 $0 $646,551
Scrap Metal $16,500 $0 $19,583
Total Cost $9,227,284 $40,320 $9,650,443
As presented in the ROD, these costs were calculated as order-of-magnitude

engineering cost estimates expected to be within +50 to -30 percent of actual project
________________________________________________________________________
VII. BLIOGRAPHY
Burns & McDonnell Engineering Company, Inc., 2006. Remedial Investigation Report,
Hudson Refinery, Cushing, Oklahoma, September.
Burns & McDonnell Engineering Company, Inc., 2007. Feasibility Study Report, Hudson
Refinery, Cushing, Oklahoma, March.
The Benham Companies, LLC, Contractor for Land OLakes, 2010a. January 2010
Groundwater Sampling Results, March 4.
The Benham Companies, LLC, Contractor for Land OLakes, 2010b. Remedial Design
and Supporting Stand Alone Documents, March 29.
The Benham Companies, LLC, Contractor for Land OLakes, 2010c. Final Field Sample
Plan, (includes Surface Water and Groundwater Monitoring Plan, as Appendix B). April
30.
The Benham Companies, LLC, Contractor for Land OLakes, 2010d. The Perimeter Air
Monitoring Plan, April 30.
The Benham Companies, LLC, Contractor for Land OLakes, 2010e. Discharge
Monitoring Report Forms April 2010, May 14.
The Benham Companies, LLC, Contractor for Land OLakes, 2010f. April 2010
Groundwater Sampling Results, June 8.
The Benham Companies, LLC, Contractor for Land OLakes, 2010g. Discharge
Monitoring Report Forms May 2010, June 16.
The Benham Companies, LLC, Contractor for Land OLakes, 2010h. Discharge
Monitoring Report Forms June 2010, July 13.
The Benham Companies, LLC, Contractor for Land OLakes, 2010i. Discharge
Monitoring Report Forms July 2010, August 15.
The Benham Companies, LLC, Contractor for Land OLakes, 2010j. Discharge
Monitoring Report Forms August 2010, September 15.
The Benham Companies, LLC, Contractor for Land OLakes, 2010k. July 2010
Groundwater Sampling Results, September 17.
The Benham Companies, LLC, Contractor for Land OLakes, 2010l. Discharge
Monitoring Report Forms September 2010, October 15.
________________________________________________________________________
Ecology and Environment, Inc. (E&E), 1999. Expanded Site Inspection Report for
Hudson Refinery, Cushing, Payne County, Oklahoma, May.
Envirocon, Contractor for Land OLakes 2010. Remedial Action Work Plan, May 28.
Lockheed Environmental Systems and Technologies Co., 1999. Aerial Photographic

Analysis of the Hudson Refinery Site, Cushing, Oklahoma. Prepared for U.S. EPA,
Region 6, June 1999.
ODEQ), 2003. Consultant Scope of Work for the Remedial Investigation/Feasibility Study
(RI/FS) for the Hudson Refinery Superfund Site, November 21.
ODEQ, 2009. Effluent limits and monitoring frequencies for the Hudson Refinery
Superfund Site (Discharge Authorization), November 23.
Oklahoma Department of Transportation (ODOT), 1991. Initial Site Assessment, SH 33

Relocation through US RAM Refinery City of Cushing, Payne County Oklahoma, March.
Oklahoma Administrative Code, 2009, OAC 252:205, July 1.
Oklahoma Statute, 1993. Title 27A-1 (Oklahoma Hazardous Waste Management Act).
Oklahoma Water Resources Board (OWRB), 2010. OWRB Regulations Title 785,
Chapter 35 (OAC 785:35:11), May 27 (amended).
Penn, E., On-Site Construction Project Manager representing Land OLakes, 2010.
Electronic mail transmission, Hudson ACM volume and Pre-final Inspection, October
9.
Shaw Environmental, Inc. (Shaw), 2004. Final Non-Time-Critical Removal Action

Report, Hudson Oil Refinery Superfund Site, Cushing, Oklahoma, January.
Starns, B. E., Project Coordinator representing Land OLakes, 2009a. Land OLakes, Inc.
Report on Site Access and Best Efforts to Obtain Site. March 6.
Starns, B. E., Project Coordinator representing Land OLakes, 2009b. Land OLakes, Inc.
First Supplemental Report on Site Access and Best Efforts to Obtain Site. April 1.
Starns, B. E., Project Coordinator representing Land OLakes, 2009c. Land OLakes, Inc.
Second Supplemental Report on Site Access and Best Efforts to Obtain Site. June 4.
Starns, B. E., Project Coordinator representing Land OLakes, 2009d. Land OLakes, Inc.
Third Supplemental Report on Site Access and Best Efforts to Obtain Site. July 9.
________________________________________________________________________
Starns, B. E., Project Coordinator representing Land OLakes, 2009e. Land OLakes, Inc.
Fourth Supplemental Report on Site Access and Best Efforts to Obtain Site. September
11.
Starns, B. E., Project Coordinator representing Land OLakes, 2009f. Land OLakes, Inc.
Fifth Supplemental Report on Site Access and Best Efforts to Obtain Site, September
28.
Starns, B. E., Project Coordinator representing Land OLakes, 2010a. Piping

Encountered During Excavation of Visual Contamination, July 1.
Starns, B. E., Project Coordinator representing Land OLakes, 2010b. Design

Modifications, Field Variations & Clarifications Approved in the Field. October 26.
Starns, B. E., Project Coordinator representing Land OLakes, 2010c. Electronic mail
transmission, Estimates for PCOR, November 17.
State of Oklahoma, Payne County, Register of Deeds, 2009. Quit Claim Deed, I-2009-
006828, Book 1836, Pages 0918-0918, June 8.
State of Oklahoma, Payne County, Register of Deeds, 2010a. Quit Claim Deed, I-2010-
000499, Book 1872, Pages 0079-0080, January 15.
State of Oklahoma, Payne County, Register of Deeds, 2010b. Quit Claim Deed, I-2010-
007852, Book 1897, Pages 0652-0655, June 29.
State of Oklahoma, Payne County, Register of Deeds, 2010c. Quit Claim Deed, I-2010-
007853, Book 1897, Pages 0656-0657, June 29.
US District Court, Western District of Oklahoma, 1987. United States of America v.

Hudson Refining Co., Inc., Hudson Oil Co., Inc., Civil Action No. 84-2027-A, Final
Consent Decree, December 11.
US District Court, Western District of Oklahoma, 1994. United States of America v.

Hudson Refining Co., Inc., Hudson Oil Co., Inc., No. CIV-84-2027-A, Order for Closure
of the Final Consent Decree, October 25.
USEPA, 2007. Record of Decision Hudson Refinery Superfund Sites OKD082471988

Cushing, Oklahoma, November 23.
USEPA, 2008. Close Out Procedures for National Priorities List Sites, OSWER
Directive 9320.2-09A-P, January.
USEPA, 2008. Framework for Investigating Asbestos-Contaminated Superfund Sites,

OSWER Directive #9200.0-68, September.
________________________________________________________________________
USEPA, 2009. Administrative Order for Remedial Design and Remedial Action [Hudson
Oil Refinery Land OLakes Incorporated Respondent CERCLA Docket No. 06-16-
08], January 6.
USEPA, 2010a. Pre-final Inspection Record, Project: Hudson Refinery Superfund Site,
Inspection Date: October 19, 2010, October 25.
USEPA, 2010a. Explanation of Significant Differences, November 19, 2010.
Williams Brothers Waste Control, Inc., 1974. Rainfall and Surface Water Runoff Survey,
Report WBWC 3094, September.
________________________________________________________________________
Attachment 1
Site Figures
________________________________________________________________________
Site Location

Figure 1
LEGEND
0 500 1,000 2,000 SITE LOCATION MAP
Site Boundary Feet HUDSON OIL REFINERY
SUPERFUND SITE
CUSHING, OK
Attachment 2
Remediation Summary
________________________________________________________________________
Hudson Refinery Superfund Site
Remediation Progress Summary
Post-Ex 1 Additional Post-Ex 2 Approved For Backfilling Estimated

Remediation Category Areas Excavated Sampled Excavation Sampled VC Chem Exceed Backfilled Volume Yd3
Updated: October 12, 2010

Surface Impoundments - Chem Exceedances AP-7 100% 100% NR NR Yes Yes 100% 1,706
WWP-1 100% 100% 100% 100% Yes Yes 100% 4,747
WWP-2 100% 100% NR NR Yes Yes 100% 7,441
WWP-3 100% 100% NR NR Yes Yes 100% 369
Coke Pond 100% 100% 100% 100% Yes Pending 75% 6,502
Soil - Chem Exceedances SAOC-1-1 100% 100% 100% 100% Yes Yes 100% 251
SAOC-1-2 100% 100% NR NR Yes Yes 100% 275
SAOC-1-3 100% 100% 100% 100% Yes Yes 100% 620
SAOC-1-4 100% 100% 100% 100% Yes Yes 100% 460
SAOC-1-5 100% 100% NR NR Yes Yes 100% 575
SAOC-1-6 100% 100% 100% 100% Yes Yes 100% 320
SAOC-1-7 100% 100% 100% 100% Yes Yes 100% 166
SAOC-1-8 100% 100% NR NR Yes Yes 100% 99
SAOC-2-2 100% 100% NR NR Yes Yes 100% 379
Sampled 9-27-10 SAOC-2-3 100% 100% 100% 100% Yes Yes 100% 300
SAOC-2-6 100% 100% 100% 100% Yes Yes 100% 98
Sampled 9-27-10 SAOC-2-7 100% 100% 100% 100% Yes Yes 100% 233
SAOC-2-15 100% 100% 100% 100% Yes Yes 100% 455
SAOC-3-5 100% 100% 100% 100% Yes Yes 100% 739
Consumed in western expansion of Coke Pond SAOC-4-4 100% NR NR NR Yes SO 0% 220
SAOC-4-6 100% 100% NR NR Yes Yes 100% 268
SAOC-5-1 100% 100% NR NR Yes Yes 100% 274
SAOC-7-1 100% 100% NR NR Yes Yes 100% 475
Soil - VC SAOC-1/BH-09 100% 100% 100% NR Yes Yes 100% 320

SAOC-2/BH-04 100% 100% NR NR Yes Yes 100%
SAOC-2/BH-14 100% 100% NR NR Yes Yes 100%
SAOC-2/HSBH-09 100% 100% NR NR Yes Yes 100% 458
SAOC-2/HSBH-11 100% NR NR NR Yes Yes 100% 0
SAOC-2/HSBH-16 100% NR NR NR Yes - Not VC Yes - Not VC 100% 0
SAOC-2/HSBH-17 100% NR NR NR Yes NR 100% 0
SAOC-2/Pothole #9 100% 100% 100% 100% Yes Yes 100% 218
SAOC-3/BH-02 100% 100% NR NR Yes Yes 100% 215
SAOC-3/HSBH-09 100% 100% 100% 100% Yes Yes 100% 482
C:\DOCUME~1\lstankos\LOCALS~1\Temp\notesE1EF34\Remediation Progress Summary_10-12-10

Hudson Refinery Superfund Site
Remediation Progress Summary
Post-Ex 1 Additional Post-Ex 2 Approved For Backfilling Estimated

Remediation Category Areas Excavated Sampled Excavation Sampled VC Chem Exceed Backfilled Volume Yd3
SAOC-3/HSBH-10 100% 100% 100% 100% Yes Yes 100% 171
SAOC-3/Pothole #7 100% 100% NR NR Yes Yes 100% 125
Consumed in expansion of Coke Pond Berm SAOC-4/BH-01 100% NR NR NR Yes SO 0%
Consumed in Coke/Tar Area SAOC-4/BH-02 100% 100% NR NR Yes SO 0%
Consumed in expansion of Coke Pond Berm SAOC-4/BH-03 100% NR NR NR Yes SO 0% 100
SAOC-5 100% 100% NR NR Yes Yes 100%
SAOC-6 (VC assessmt) 100% NR NR NR Yes - Not VC Yes - Not VC 100%
SAOC-7/Pothole #16 100% NR NR NR Yes - Not VC Yes - Not VC 100% 0
SAOC-7/Pothole #17 100% NR NR NR Yes - Not VC Yes - Not VC 100% 0
Coke Tar/Pothole #2 100% 100% NR NR Yes Yes 0% 538
Coke Tar/Pothole #4 100% 100% NR NR Yes Yes 0% 538
Coke Pond Berm 100% 100% NR NR Yes Pending 75% 24,372
Unnamed Seep #1 100% 100% NR NR Yes Yes 100% 68
Notes: Estimated Cumulative Volume in Cubic Yards 54,719
VC - Denotes visual contamination
NR - Denotes not required Estimated Cumulative Volume in Cubic Yards Based on Landfill Tons 61,162
SO - Sample with other area
C:\DOCUME~1\lstankos\LOCALS~1\Temp\notesE1EF34\Remediation Progress Summary_10-12-10

Attachment 3
Pre-final Inspection Record
________________________________________________________________________
PRE-FINAL INSPECTION RECORD
Project: Hudson Refinery Superfund Site Inspection Date: October 19, 2010
Summary of Inspection:
On October 19, 2010, a pre-final inspection was conducted at the Hudson Refinery Superfund Site (Site) in Cushing,
Oklahoma to evaluate Remedial Action (RA) construction. The inspection started at 10:00 am. Heavy rains prevented a
physical site inspection in the morning and extensive muddy site conditions prevented fully driving the Site in the afternoon
after the rain ceased. The inspection meeting was held in the Benham Site trailer.
Waste and Contaminated Media Removal:

The final package of soil confirmation results was received from the laboratory on October 18, 2010; these results were for two
areas that had to be re-excavated due to an arsenic soil cleanup level exceedence or a benzo(a)pyrene laboratory detection level
exceedence. The results showed that cleanup levels had been met for these two areas.
Waste and contaminated media (Asbestos-Containing Material (ACM), Coke Tar, and Scrap Metal, Soil, Sediment, and
Surface Water) have been removed from the Site. Ground water monitoring is on-going.
Site Work Status Report (Eldon Penn):

North Refinery berm between Ponds 5 and 6 being graded into the slope and shaping; re-vegetation subcontractor disking
and prepping for seeding; outflow structure for Ponds 8 and 9 being worked, waiting until after rain events to breach berm; and
construction debris removal
South Refinery backfill complete; need to confirm cover depth with survey and survey for final shaping; hand sweeping for
debris removal and address impacts for mowing; will disk and prep for seeding after area dries from rain
Dennis Datin - Question on how long seeding and sodding will take approximately one week of work time. A semi-truck
will deliver the sod to the Site area; the semi cannot deliver if the Site is too wet. Rain is forecast for the weekend; re-
vegetation work will need to hold off until site conditions are assessed. Need dry weather to complete work. Hay bales and
rip-rap is in place to address siltation and erosion control.
Grading Plan (Bill Torneten):

Wastewater pond terracing changed to a gentle slope for the wastewater pond area with sediment retention in Pond 6 until re-
vegetation. No slope is greater than 9-10%. Pond 6 will capture runoff from a 20 acres area. The outflow from Pond 6 goes
through the RR easement. The RR culvert collapsed the previous 4-foot pipe has been throttled down to a 2-foot pipe.
Grading of Ponds 8 and 9 the horizontal pipe structure was removed and weir structure will be replaced with a new concrete
headwall. 18-foot principal spillway is in place to work in conjunction with pond pipe outflow. These ponds will capture
runoff from the South Refinery and off-site upgradient areas (not detailed hydrology conceptual). The box culvert under
Depot St. will remain. The runoff co-efficient from the RD may have changed but the drainage area has not really changed.
Re-vegetation (Eldon Penn):

The re-vegetation contractor recommended fescue seeding for the winter. It is more permanent with a better root structure than
winter rye; also rye dies out. The sloped areas will be sodded. The fescue will work in tandem with a spring application of a
permanent cover of Bermuda; the combination will work toward a pasture scenario. The sod will help control erosion even if
sod winter die-off occurs. The sod areas will be evaluated in the spring and dead areas will be re-sodded.
Site Roads (Eldon Penn):

The main road on the North Refinery has been reinforced; the road up to the wastewater pond area has road fabric and crushed
rock. There are compacted areas on the South Refinery that served as roads these will not be reinforced. The road associated
with the RR trestles will be removed.
Fencing (Eldon Penn):

Fence around perimeter will be re-installed in areas where it has been removed. LOL has concern for Site security and also to
prevent dumping.
Byron Starns Questions What are future fencing requirements? South Refinery landowners want fencing to mark internal
property boundaries. Answer - Once the re-vegetation and erosion control work is completed, fence maintenance will be
landowner responsibility. Access and security will need to be maintained to address ground water contamination and for
ground water monitoring. As the primary North Refinery landowner, LOL can maintain the fence as it sees fit. South Refinery
landowner-requested internal fencing is not required.
Ground Water (Laura Stankosky/Dennis Datin):
Concern that monitoring well MW-4 had LNAPL with the last round of ground water sampling (OW-D was the well with
historical LNAPL). The water level and screened interval for this well were discussed. It is not clear where the LNAPL lies
in the alluvial deposits or the deeper sandstones (Van Noss formation); it is not clear that LNAPL is does not have the potential
of future off-site migration or to migrate downgradient or laterally.
Monitoring well OW-B has had benzene levels 2 orders of magnitude above the Remedial Investigation level of 9.0 ppb. OW-
B was aggressively re-developed during the initial RD sample event. The levels observed during RD/RA sampling were as
follows: 10/09 665 ppb, 1/10 413 ppb, 4/10 139 ppb, and 7/10 193 ppb. It is not clear if there is an upgradient source
that caused the benzene increase; benzene does not meet ROD performance standard that the areas with contamination are
stable and/or decreasing. The potential of future off-site migration of benzene contamination is not clear.
Additional wells were discussed to more fully define LNAPL contamination and to ensure that there is no movement into off-
site areas. Additional wells were discussed to identify if a benzene source lays upgradient of OW-B and downgradient to
determine if benzene has the potential to migrate off-site. Note: From a review of Supporting Stand Alone Documents,
specifically the Surface Water and Ground Water Monitoring Plan, it appears that this plan is the appropriate plan to update to
describe the installation of wells for LNAPL and benzene monitoring.
Properly Plugging and Abandoning Site monitoring wells (Laura Stankosky/Dennis Datin):
Discussed OWRB rules that require that unused wells be properly P&Ad. The Site monitoring wells need to be evaluated to
determine if they will be part of the Site ground water long-term monitoring program as part of the SOW-required update of
the Operation and Maintenance (O&M) Plan. Wells that will not be used should be properly P&Ad. David Brady asked if the
wells needed to sample prior to P&A. Answer It is common practice to sample prior to P&A; once the well has been P&Ad
it is gone. It was left open for discussion.
The large production well discovered during the RD was discussed. This well is adjacent to monitoring well, OW-B. The
condition of the casing of this production well is not known; there could be a risk of benzene contamination migrating into the
deeper aquifer formation. It was also discussed that open holes create a liability and an opportunity for illegal
dumping/disposal of contamination into unsecured wells. The OWRB rules pertain to the large production well.
EPA Response to Notice of Anticipated Delay schedule items questions (Byron Starns/Laura Stankosky)
EPA answered questions on the schedule items in the EPA response letter. Progress reports weekly needed through
demobilization of equipment; monthly through the winter and until re-vegetation completed. Progress reports submitted as part
of O&M should be updated in the O&M Plan. Note ICs are part of the remedy and the schedule must include. Dennis Datin
indicated that Barbara Rauch was the contact for drafting and filing deed notices.
Site Drive afternoon (Laura Stankosky/Dennis Datin/Philip Allen/Stan Wallace):

The Site was too muddy to drive on-site. The external city roads were driven for a Site inspection. The only issue noted that
was not discussed in the morning was a small amount of standing water was observed in the graded area on the South Refinery
where excavation for SAOC4/Coke Tar/Coke Pond had occurred.
Punch List Items:

Disking and re-vegetation/seeding of the backfilled/graded areas on the North Refinery with fescue
Final grading, elimination of areas that may hold water, and survey
Re-vegetation/seeding of the backfilled areas on the South Refinery with fescue
Erosion control measures through winter
Completion of pond grading
Completion of drainage outfalls
Replacement and repair of Site fencing
Demobilization of heavy equipment and Site trailers
Site mowing
Management of Site through winter months
Springtime re-vegetation/seeding with permanent cover (Bermuda) and any needed erosion control measures
(including replacement of sod on sloped areas)
Filing of Institutional Controls
Update of Surface Water and Ground Water Monitoring Plan for well installation
Installation of wells to ensure LNAPL ROD performance standards are met
Installation of wells to ensure benzene ROD performance standards are met
Evaluation of Site wells for ground water monitoring for benzene and LNAPL; P&A all Site wells not used
for monitoring or as part of O&M
Update of O&M Plan
Progress reports.
Additional Pre-final Inspection Yes X No
Participants:
EPA Remedial Project Manager Laura Stankosky
EPA Representative Philip Allen
ODEQ Project Manager Dennis Datin
Land OLakes Project Coordinator Byron Starns, Leonard, Street, and Deinard
EPA Oversight Contractor Stan Wallace, EA
Independent Quality Assurance Team Tom Knudson/Phil Wood, Terracon
RA Project Manager Eldon Penn, Envirocon
RA Site Superintendent Rich Clapp, Envirocon
RD Project Manager Jack Lawmaster, Benham
RA Sampling David Brady, Benham
Site Engineer Bill Torneten, Benham
Additional Participants Mark Coldiron/Steve Jantzen, RWCS

Superfund Document

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Superfund Document

Uploaded by

Copyright:

Available Formats

PRELIMINARY CLOSE OUT REPORT

U.S. ENVIRONMENTAL PROTECTION AGENCY

On October 19, 2010, the EPA, the Oklahoma Department of Environmental

II. SUMMARY OF SITE CONDITIONS

Over sixty years of refinery operations resulted in environmental contamination at

The refinery expanded in size during its ownership by Midland Cooperatives.

Site Investigations and Response Actions

As part of the proposed relocation of SH 33 through the Hudson Refinery, an

On September 25, 2001, EPA signed a non-time critical Removal Action

Remedial Investigation/Feasibility Study (RI/FS)

Onsite hazardous substances and contamination were identified in soil, sediment,

Benzo(a)pyrene (BaP), arsenic, and lead were the principal contaminants of

Table 1 Remedial Action Objectives

In order to achieve these RAOs, numerical risk-based cleanup levels were

Media: Surface Water

Based on the investigation of Site historical information, five Special Notice

LOL, Inc., a Minnesota corporation, is the surviving corporation of Midland,

Benham submitted the Pre-Final Design on February 1, 2010, and submitted a

The Basis of Design section in the RD described pond drainage to expose

To expedite Site RA activities, Envirocon submitted RA work plans in phases.

Mobilization to the site for Phase I remedial construction activities began

Monthly Progress Reports and Weekly Communications Memos were prepared

As described in the ROD, solidification measures were required for wastewater

During Site clearing and grubbing and RA construction activities, an additional

A Remediation Summary table was produced weekly to identify the status of

Ground water monitoring was conducted on a quarterly basis through the RA

The following RA work items were determined to be complete:

Clearing and Grubbing;

Disking and re-vegetation/seeding of the backfilled/graded areas on the

Explanation of Significant Differences

An Explanation of Significant Differences (ESD) was signed on November 19,

III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE

The EPA and ODEQ conducted continued oversight during RA construction

IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION

The following RA work activities will be completed according to the schedule

V. SUMMARY OF REMEDIATION COSTS

Table 4: Estimated Cost for the Selected Remedy

As presented in the ROD, these costs were calculated as order-of-magnitude

Lockheed Environmental Systems and Technologies Co., 1999. Aerial Photographic

Oklahoma Department of Transportation (ODOT), 1991. Initial Site Assessment, SH 33

Oklahoma Administrative Code, 2009, OAC 252:205, July 1.

Shaw Environmental, Inc. (Shaw), 2004. Final Non-Time-Critical Removal Action

Starns, B. E., Project Coordinator representing Land OLakes, 2010a. Piping

Starns, B. E., Project Coordinator representing Land OLakes, 2010b. Design

US District Court, Western District of Oklahoma, 1987. United States of America v.

US District Court, Western District of Oklahoma, 1994. United States of America v.

USEPA, 2007. Record of Decision Hudson Refinery Superfund Sites OKD082471988

USEPA, 2008. Framework for Investigating Asbestos-Contaminated Superfund Sites,

USEPA, 2010a. Explanation of Significant Differences, November 19, 2010.

Post-Ex 1 Additional Post-Ex 2 Approved For Backfilling Estimated

Updated: October 12, 2010

Soil - VC SAOC-1/BH-09 100% 100% 100% NR Yes Yes 100% 320

C:\DOCUME~1\lstankos\LOCALS~1\Temp\notesE1EF34\Remediation Progress Summary_10-12-10

Post-Ex 1 Additional Post-Ex 2 Approved For Backfilling Estimated

C:\DOCUME~1\lstankos\LOCALS~1\Temp\notesE1EF34\Remediation Progress Summary_10-12-10

Waste and Contaminated Media Removal:

Site Work Status Report (Eldon Penn):

Grading Plan (Bill Torneten):

Re-vegetation (Eldon Penn):

Site Roads (Eldon Penn):

Fencing (Eldon Penn):

Site Drive afternoon (Laura Stankosky/Dennis Datin/Philip Allen/Stan Wallace):

Punch List Items: